Facilities preparing for an SQF Edition 10 audit are quickly discovering that minor gaps can lead to major audit findings. Areas that may have received limited scrutiny in previous editions, such as employee competency, verification follow-through, and food safety culture, are now receiving far greater attention from auditors. Many facilities appear audit-ready on paper, but inconsistencies between documented programs and daily operations continue to create risk.
As auditors place greater emphasis on system effectiveness, facilities are uncovering common gaps in documentation, training, verification activities, and risk assessments that could lead to nonconformances if left unaddressed.
Common Gap #1: Documentation That Doesn’t Match Current Practices
Outdated or inconsistent documentation remains one of the most common audit issues. Examples of this include:
- SOPs referencing equipment that is no longer used
- Multiple versions of logs being used across different departments
- Outdated HACCP plans
Edition 10 places strong emphasis on implementing successful systems. Auditors are looking for proof that what the facilities documents show is actually happening. The records demonstrate that the facility has successfully implemented written plans. Additionally, the new Code prominently features risk-based thinking. For instance, outdated documents could mean that the facility is not properly assessing hazards.
Simple Habits to Prevent Documentation Inconsistency:
- Schedule quarterly document reviews
- Assign document ownership
- Conduct floor-to-document comparisons regularly
- Involve supervisors and floor employees in reviews
Common Gap #2: Training Records, Employee Competency, and Food Safety Culture
A major element of SQF Edition 10 is food safety culture. The new Code includes the implementation of a Food Safety Culture Assessment Plan. This plan evaluates how effectively cultural elements, such as values and behaviors, support food safety objectives. It also identifies risks posed by a substandard culture to food safety systems.
“A food safety culture is the shared values, beliefs, and norms that affect mindset and behavior toward food safety, across and throughout an organization.” – GFSI (2018)
Edition 10 takes food safety culture to the next level. It’s not only about documenting that you have food safety culture processes, but it’s also about whether everyday behaviors actually support food safety in practice. Auditors will look for evidence that the food safety culture is actively supported.
Best Practices:
- Cross-train personnel on food safety responsibilities
- Maintain easy-to-access training records in advance for audits
- Verify employee competency with observations or quizzes
- Review training effectiveness during internal audits
Common Gap #3: Verification Activities That Lack Follow-Through
Verification failures often occur when facilities perform checks but fail to document review and corrective action. An audit finding related to this occurs when there is insufficient evidence that results are being reviewed or acted upon. Auditors are taking a closer look at verification activities to determine whether facilities use them to improve food safety systems rather than simply record them.
One benefit of follow-through is that it allows facilities to identify patterns of issues that they would have previously missed. Individual results make it hard to identify systemic problems. Edition 10 emphasizes system effectiveness, while verification is the expectation of confirming that the controls are in place and working effectively.
Common Gap #4: Outdated Risk Assessments
Facilities need to review and update risk assessments regularly. The assessment should occur at a minimum when processes, suppliers, or regulations change. However, facilities often overlook the need to reevaluate risk. When facilities introduce new products, ingredients, or suppliers but fail to update their HACCP Plan, they create a common weakness.
Suggested Actions:
- Trigger reassessments when operational changes occur, such as
- New products
- New ingredients
- Supplier changes
- Process flow changes
Where Facilities Commonly Struggle During the Transition to Edition 10
While the transition to Edition 10 can feel overwhelming, facilities can manage it successfully with proactive planning and cross-functional coordination. Facilities need to take an active approach to this transition. This process requires time, coordination, and clarity.
One of the most common struggles facilities face is shifting their mindset from documentation-focused to a systems-based, culture-driven focus. The biggest challenges are typically operational, not procedure-based.
Quick SQF Edition 10 Self-Assessment Checklist
Below is a checklist of items to perform a self-assessment against SQF Edition 10. After your assessment, if multiple areas raise concern, it may be time for a more comprehensive readiness assessment.
Documentation & Change Management
- Are SOPs aligned with day-to-day operations?
- Have outdated forms been removed from use?
- What is the documented process for assessing updates after process changes?
Training & Employee Competency
- Are training records complete and easy to access?
- Are employees able to explain food safety procedures?
- Have all employees received the necessary training?
Food Safety Culture
- Is there active participation in food safety systems?
- Is management involved in supporting food safety policies?
- What evidence is there supporting your Food Safety Culture Plan?
Verification & Corrective Actions
- Are corrective actions verified?
- Are internal audit findings significant?
- Are records regularly reviewed?
Risk Assessments
- Have assessments recently been reviewed?
- Allergen
- Food Defense
- Food Fraud
- Environmental Monitoring
- Are risk assessments up to date?
- Are reassessments in place for operational changes?
Audit Readiness
- How quickly can records be accessed during an audit?
- Do employees feel confident in answering auditor questions?
- When was the last internal audit performed?
Quick SQF Edition 10 Self-Assessment Checklist
Below is a checklist of items to perform a self-assessment against SQF Edition 10. After your assessment, if multiple areas raise concern, it may be time for a more comprehensive readiness assessment.
Documentation & Change Management
- Are SOPs aligned with day-to-day operations?
- Have outdated forms been removed from use?
- What is the documented process for assessing updates after process changes?
Training & Employee Competency
- Are training records complete and easy to access?
- Are employees able to explain food safety procedures?
- Have all employees received the necessary training?
Food Safety Culture
- Is there active participation in food safety systems?
- Is management involved in supporting food safety policies?
- What evidence is there supporting your Food Safety Culture Plan?
Verification & Corrective Actions
- Are corrective actions verified?
- Are internal audit findings significant?
- Are records regularly reviewed?
Risk Assessments
- Have assessments recently been reviewed?
- Allergen
- Food Defense
- Food Fraud
- Environmental Monitoring
- Are risk assessments up to date?
- Are reassessments in place for operational changes?
Audit Readiness
- How quickly can records be accessed during an audit?
- Do employees feel confident in answering auditor questions?
- When was the last internal audit performed?
Conclusion
Facilities can easily fix small gaps when they are identified and addressed early, rather than waiting for them to be found during the next audit. SQF Edition 10 requires Companies to demonstrate that food safety systems are consistently implemented, verified, and supported throughout daily operations.
Successful facilities actively address food safety by continuously verifying systems, updating documentation as changes occur, and reinforcing employee competency across the organization. For facilities looking to better prepare for the transition to Edition 10, additional training and guidance can help teams identify gaps early and build a practical implementation plan. Safe Food Alliance’s SQF Conversion Course is designed to help facilities understand the updated requirements and create a transition plan they can implement right away. View the upcoming courses here.
